EPA Lead-Safe (RRP) Certification for Painters: Working on Pre-1978 Homes in Florida

Plenty of South Florida homes were built before 1978, the cutoff year the federal lead paint rules use. When a painting job on one of them involves scraping, sanding or removing painted surfaces, the federal Renovation, Repair and Painting (RRP) rule usually applies. Here is when it applies and what it asks of a painting business.

When the rule applies

The rule covers renovations done for pay in “target housing,” which is housing built before 1978, and in child-occupied facilities such as day cares and preschools in pre-1978 buildings (40 CFR 745.82; 745.103). For painters, the key point is that “renovation” includes surface preparation like sanding and scraping (745.83). Some exceptions:

• Minor repair and maintenance: disturbing 6 square feet or less of painted surface per room inside, or 20 square feet or less outside. Window replacement and demolition never count as minor, and jobs in the same room within 30 days count as one job.
• Tested lead-free: a certified inspector or risk assessor, or a certified renovator with an EPA-recognized test kit or lab samples, found the components free of lead-based paint.
• Certain housing for the elderly or people with disabilities, and studio-type dwellings, unless a child under 6 lives there.

The Florida Department of Health notes that the rule generally does not apply to homeowners working on their own homes, but does apply to someone who rents out a home, runs a child care in it, or flips houses (FDOH).

Two certifications: the firm and the renovator

• The firm. Since April 22, 2010, a firm may not perform, offer or claim to perform covered renovations without EPA firm certification. Florida is not one of the states that runs its own RRP program, so certification comes from EPA. It lasts five years (EPA).
• The renovator. Each covered job must be directed by a certified renovator, an individual who completed an EPA-accredited course. Other workers must be certified or trained on the job by the certified renovator.

What the rule asks on the job

1. Before work: give the owner the EPA pamphlet Renovate Right no more than 60 days before starting, and get a signed acknowledgment or a certificate of mailing at least 7 days ahead. In a rental, an adult occupant gets one too (745.84).
2. Set up: post warning signs and contain the work area so no dust or debris leaves it (745.85).
3. Prohibited practices: no open-flame burning, no power sanding or grinding unless the tool has a shroud and HEPA vacuum attachment, and no heat gun at 1,100°F or more.
4. Clean up and verify: follow the cleaning and cleaning verification steps in the rule before you leave.
5. Keep records for 3 years (745.86).

Why it matters for your insurance

When we quote a painting business, we ask what kind of work you do and on what kind of buildings. Tell us if you work on pre-1978 homes, whether your firm is RRP-certified, and how you handle surface prep. Lead-related claims are a topic many liability policies address specifically, so read that part of your policy and ask us to walk you through it. See our painting contractor insurance page for coverage, and our article on helpers and workers’ comp if you bring on crew.